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Category:CORRESPONDENCE-LETTERS
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span ML20217M5711999-10-20020 October 1999 Forwards Insp Repts 50-445/99-15 & 50-446/99-15 on 990822- 1002.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as non-cited Violations Consistent with App C of Enforcement Policy TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20212L2891999-10-0101 October 1999 Discusses Closeout of GL 97-06, Degradation of Steam Generator Internals. Purpose of GL Was to Obtain Info That Would Enable NRC to Verify That Condition of Licensee SG Internals Comply with Current Licensing Bases TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 ML20212F7481999-09-24024 September 1999 Forwards SER Authorizing Relief from Exam Requirement of 1986 Edition ASME Code,Section XI Pursuant to 10CFR50.55a(a)(3)(ii) for Relief Request A-3 & 10CFR50.55a(g)(6)(i) for Relief Requests B15,16,17 & C-4 ML20212F1041999-09-23023 September 1999 Requests That NRC Be Informed of Any Changes in Scope of Y2K System Deficiencies Listed or Util Projected Completion Schedule for Comanche Peak Steam Electric Station,Units 1 & 2 ML20212E6661999-09-21021 September 1999 Advises That Info Contained in Application & Affidavit, (CAW-99-1342) Re WCAP-15009,Rev 0, Comache Peak Unit 1 Evaluation for Tube Vibration Induced Fatigue, Will Be Withheld from Public Disclosure ML20212D9111999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of CPSES & Did Not Identify Any Areas in Which Performance Warranted Insp Beyond Core Insp Program.Core Insp Plan at Facility Over Next 7 Months.Insp Plan Through March 2000 Encl ML20212A7601999-09-14014 September 1999 Forwards Insp Repts 50-445/99-14 & 50-446/99-14 on 990707-0821.Four Violations Occurred & Being Treated as Ncvs.Conduct of Activities Was Generally Characterized by safety-conscious Operations & Sound Radiological Controls TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211P3761999-09-0707 September 1999 Ack Receipt of Ltr Dtd 990615,transmitting Rev 30 to Physical Security Plan,Per 10CFR50.54(p).No NRC Approval Is Required ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211J3801999-08-27027 August 1999 Forwards Corrected TS Page 3.8-26 to Amend 66 to Licenses NPF-87 & NPF-89,respectively.Footnote on TS Page 3.8-26 Incorrectly Deleted ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20211B2861999-08-18018 August 1999 Forwards Insp Repts 50-445/99-13 & 50-446/99-13 on 990720- 23.No Violations Noted.Insp Included Implementation of Licensee Emergency Plan & Procedures During Util Biennial Emergency Preparedness Exercise ML20211C4661999-08-18018 August 1999 Discusses Proprietary Info Re Thermo-Lag.NRC Treated Bisco Test Rept 748-105 as Proprietary & Withheld It from Public Disclosure,Iaw 10CFR2.790 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety ML20211C4571999-08-16016 August 1999 Forwards Omitted Subj Page of Contractor TER TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210R2221999-08-12012 August 1999 Forwards Insp Repts 50-445/99-10 & 50-446/99-10 on 990510-0628.Violations Noted & Being Treated as Ncvs, Consistent with App C of Enforcement Policy ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210K2321999-07-29029 July 1999 Forwards Insp Repts 50-445/99-12 & 50-446/99-12 on 990530-0710.No Violations Noted ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210D8231999-07-23023 July 1999 Forwards Safety Evaluation of Relief Requests Re Use of 1998 Edition of Subsections IWE & Iwl of ASME Code for Containment Insp ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20210C3331999-07-16016 July 1999 Forwards Exam Repts 50-445/99-301 & 50-446/99-301 on 990618- 24.Exam Included Evaluation of Six Applicants for Senior Operator Licenses ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 1999-09-07
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARTXX-9924, Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span1999-10-22022 October 1999 Forwards Responses to Questions by NRC Re Application for Amends to Licenses NPF-87 & NPF-89,by Incorporating Changes Increasing RWST low-level Setpoint from Greater than But Equal to 40% to Greater than But Equal to 45% of Span TXX-9923, Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred1999-10-15015 October 1999 Forwards Monthly Operating Repts for Sept 1999 for CPSES, Units 1 & 2,per Plant TS 5.6.4.No Failures of Challenges to PORVs of SV for Units Occurred ML20217E7951999-10-12012 October 1999 Forwards COLR for Unit 1,Cycle 8,per TS 5.6.5 ML20216J5571999-10-0101 October 1999 Provides Final Response to GL 98-01,suppl 1, Y2K Readiness of Computer Sys at Npps TXX-9922, Forwards Revised COLR, for Cycle 5 for Unit 21999-10-0101 October 1999 Forwards Revised COLR, for Cycle 5 for Unit 2 ML20212G0721999-09-24024 September 1999 Forwards Rev 4 to Augmented Inservice Insp Plan for CPSES, Unit 1. Future Changes & Revs to Unit 1 Augmented Inservice Insp Plan Will Be Available on Site ML20212H0461999-09-24024 September 1999 Forwards Rev 6 to CPSES Glen Rose,Tx ASME Section XI ISI Program Plan for 1st Interval on 990820 TXX-9921, Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC1999-09-10010 September 1999 Suppls 981221 LAR 98-010 to Licenses NPF-87 & NPF-89, Clarfying Conditions of Use Re Analytical Methods Used to Determine Core Operating Limits,Per Telcon with NRC ML20211L9871999-09-0303 September 1999 Forwards Rev 31 to Technical Requirements Manual. All Changes Applicable to Plants Have Been Reviewed Under Util 10CFR50.59 Process & Found Not to Include Any USQs TXX-9915, Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl1999-09-0303 September 1999 Responds to 990701 & 0825 RAI Telcons Re Spent Fuel Pool Temp,Per LAR 98-008,which Requested Increase in Spent Fuel Storage capacity.Marked-up Page 4-1 of CPSES Fuel Storage Licensing Rept, Encl ML20211K2231999-08-31031 August 1999 Forwards Txu Electric Comments of Rvid,Version 2 ML20211G1081999-08-26026 August 1999 Responds to NRR Staff RAI Re Util Mar 1999 Submittal for NRC Review & Approval of Changes to CPSES Emergency Classification Procedure ML20211G7301999-08-26026 August 1999 Forwards Revs 29 & 30 to CPSES Technical Requirements Manual (Trm). Attachments 1 & 2 Contain Description of Changes for Revs 29 & 30 Respectively ML20211G3441999-08-25025 August 1999 Forwards Response to NRC RAI on LAR 98-010 for Cpses,Units 1 & 2.Communication Contains No New Licensing Commitments Re Cpses,Units 1 & 2 ML20210U3981999-08-17017 August 1999 Forwards Monthly Operating Repts for July 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs or SVs for Plant Occurred ML20211C0991999-08-17017 August 1999 Forwards Rev 3 to ASME Section XI ISI Program Plan,Unit 2 - 1st Interval, Replacing Rev 2 in Entirety TXX-9919, Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 9908021999-08-16016 August 1999 Forwards Relief Request A-3,Rev 1 to Unit 1 ISI Program,Per Conversations Between NRC & Txu Electric on 990802 ML20210R6561999-08-13013 August 1999 Forwards Response to NRR 990805 Telcon RAI Re License Amend Request 98-010,to Increase Power for Operation of CPSES Unit 2 to 3445 Mwth & Incorporating Addl Changes Into Units 1 & 2 TS ML20210S6411999-08-12012 August 1999 Informs That Wg Guldemond,License SOP-43780,is No Longer Performing Licensed Duties.Discontinuation of License Is Requested ML20210N1101999-08-0404 August 1999 Provides Supplemental Info to Util 990623 License Amend Request 99-005 Re Bypassing DG Trips.Info Replaces Info Contained in Subject Submittal in Attachment 2,Section II, Description of TS Change Request TXX-9918, Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-9906301999-08-0202 August 1999 Forwards CPSES 10CFR50.59 Evaluation Summary Rept 0008,for 970802-990201 & CPSES Commitment Matl Change Evaluation Rept 0003,for 970802-990630 ML20210J2301999-08-0202 August 1999 Forwards Amend 96 to CPSES Ufsar.Replacement of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,Rev 2 ML20210J6071999-08-0202 August 1999 Forwards line-by-line Descriptions of Changes in Amend 96 to CPSES UFSAR Transmitted by Util Ltr TXX-99166,dtd 990802. Replacment of FSAR Figures with Plant Process Flow Diagrams Meets Intent & Requirements of NRC Reg Guide 1.70,rev 2 TXX-9916, Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 9907271999-08-0202 August 1999 Notifies NRC That CPSES Units 1 & 2,improved TS Implemented on 990727 ML20210G5861999-07-29029 July 1999 Forwards fitness-for-duty Program Performance Data for Six Month Period of Jan-June 1999 ML20210J0121999-07-27027 July 1999 Forwards Summary of Methodology for Determination of NDE Measurement Uncertainty,In Response to Recent Discussions with NRC Re LAR 98-006 Concerning Rev to SG Tube Plugging Criteria TXX-9917, Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES1999-07-26026 July 1999 Provides Info Re Augmented Inservice Insp Plan,Which Requires Periodic Insp of Rv Head & Internals Lifting Devices at CPSES ML20210F3121999-07-26026 July 1999 Responds to GL 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, ML20210C2931999-07-21021 July 1999 Supplements 880323 Response to NRC Bulletin 88-02, Rapidly Propagating...Sg Tubes, Non-proprietary WCAP-15010 & Proprietary Rev 0 to WCAP-15009, CP Unit 1 Evaluation for Tube Vibration... Encl.Proprietary Rept Withheld ML20210D3211999-07-21021 July 1999 Provides List of Estimates of Licensing Actions,In Response to Administrative Ltr 99-02,dtd 990603 ML20209H2551999-07-16016 July 1999 Forwards ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2 & Containment ISI Summary Rept for Fourth Refueling Outage of CPSES Unit 2,per ASME Boiler & Pressure Vessel Code,Section Xi,Paragraph IWA-6230 ML20209H0111999-07-16016 July 1999 Forwards Relief Request C-4 to CPSES Unit 2 ISI Program for Approval ML20209G0721999-07-13013 July 1999 Forwards Monthly Operating Repts for June 1999 for CPSES, Units 1 & 2,per TS 6.9.1.5.No Failures or Challenges to PORVs of SV Occurred During Reporting Period ML20209F0681999-07-0909 July 1999 Informs That Effective 990514,TU Electric Formally Changed Name to Txu Electric.Change All Refs of TU Electric to Txu Electric on Correspondence Distribution Lists ML20209E0421999-07-0909 July 1999 Forwards Response to NRC Request for Addl Info on LAR 98-010.Attachment 1 Is Affidavit for Info Supporting LAR 98-010 ML20209B6021999-06-30030 June 1999 Submits Second Response to NRC GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Readiness Disclosure for Reporting Status of Facility Y2K Readiness Encl ML20195J6981999-06-15015 June 1999 Provides Addl Info Related to Open Issue,Discussed in 990610 Conference Call with D Jaffe Re ISI Program Relief Request L-1 Submitted by Util on 980220 ML20196A4921999-06-15015 June 1999 Forwards Rev 30 to Physical Security Plan.Rev Withheld,Per 10CFR73.21 ML20195J0491999-06-14014 June 1999 Submits Response to RAI Re Implementation of 1.0 Volt Repair Criteria ML20195J0651999-06-14014 June 1999 Submits Response to RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves 05000445/LER-1999-001, Forwards LER 99-001-00, Some Electrical Contacts for RCS Pressure Relief Valves Were Not Included in Surveillance Testing Procedures. New Licensing Commitments Identified in Attachment 11999-06-0808 June 1999 Forwards LER 99-001-00, Some Electrical Contacts for RCS Pressure Relief Valves Were Not Included in Surveillance Testing Procedures. New Licensing Commitments Identified in Attachment 1 ML20195F0091999-06-0808 June 1999 Forwards Response to RAI Re Units 1 & 2 ISI Program for Relief Requests E-1 & L-1.Communication Contains No New Licensing Basis Commitments Re Cpses,Units 1 & 2 ML20207E1921999-05-28028 May 1999 Submits Updated Request for NRC Staff to Review & Approve Certain Changes to CPSES Emergency Plan Submitted in 981015 & s Prior to Changes Being Implemented at CPSES ML20207E1711999-05-28028 May 1999 Supplements 990526 LAR 99-004 as TU Electric Believes Extingency Exists in That Proposed Amend Was Result of NOED Granted to Prevent Shudown of CPSES Unit 1 ML20207D9841999-05-26026 May 1999 Requests That NRC Exercise Enforcement Discretion to Allow Cpses,Unit 1 to Remain in Mode 1,power Operation,Without Having Performed Svc Test,Per SR 4.8.2.1d on Unit 1 Battery BT1ED2 ML20195B6351999-05-25025 May 1999 Submits Response to RAI Re GL 95-07, Pressure Locking & Thermal Binding of Safety Related Power Operated Gate Valves TXX-9912, Forwards Txu Electric (Formerly TU Electric) CPSES Emergency Preparedness Exercise Scenario Manual for 990721-22,Graded Exercise1999-05-21021 May 1999 Forwards Txu Electric (Formerly TU Electric) CPSES Emergency Preparedness Exercise Scenario Manual for 990721-22,Graded Exercise ML20206U1981999-05-20020 May 1999 Forwards Form 10K Annual Rept,Per 10CFR50.71(b). Communication Contains No New Licensing Basis Commitments Re Cpses,Units 1 & 2 ML20196L1931999-05-20020 May 1999 Forwards MOR for Apr 1999 for Cpses,Units 1 & 2.During Reporting Period There Have Been No Failures or Challenges to Power Operated Relief Valves or Safety Valves TXX-9911, Forwards non-proprietary & Proprietary Responses to RAI Re LAR 98-010 by Incorporating Attached Changes Into CPSES Unit 2 OL NPF-89 & CPSES Units 1,OL NPF-87 & 2 TS to Increase Licensed Power.W & Caldon Proprietary Responses Withheld1999-05-14014 May 1999 Forwards non-proprietary & Proprietary Responses to RAI Re LAR 98-010 by Incorporating Attached Changes Into CPSES Unit 2 OL NPF-89 & CPSES Units 1,OL NPF-87 & 2 TS to Increase Licensed Power.W & Caldon Proprietary Responses Withheld 1999-09-03
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059K6141990-09-17017 September 1990 Submits Documentation of 900906 Telcon Re Addl Util Candidate for Licensed Operator Generic Fundamentals Exam Section ML20059G8761990-09-10010 September 1990 Forwards Rev 8 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) ML20059F8461990-09-0404 September 1990 Responds to NRC Re Violations Noted in Insp Repts 50-445/90-22 & 50-446/90-22 on 900606-0705.Corrective action:OPT-467A Changed to Provide Addl Prerequisite Info Re Solid State Protection Sys Switch Lineup During Testing ML20059E4981990-08-31031 August 1990 Forwards Revised Radial Peaking Factor Limit Rept for Cycle 1 Per Tech Specs Through Amend 1 & ML20059E4201990-08-30030 August 1990 Forwards Objectives & Guidelines for 1990 Emergency Preparedness Exercise Scheduled for 901113 ML20028G8281990-08-29029 August 1990 Forwards Comanche Peak Unit 1 Semiannual Radioactive Effluent Release Rept,900403-0630 & ODCM TXX-9030, Forwards Endorsements 40 & 4 to Nelia Policy NF-274 & Maelu Policy M-90,respectively & Endorsements 10,11,12,13,14 & 15 to Maelu Policy MF-1311990-08-27027 August 1990 Forwards Endorsements 40 & 4 to Nelia Policy NF-274 & Maelu Policy M-90,respectively & Endorsements 10,11,12,13,14 & 15 to Maelu Policy MF-131 ML20059F4381990-08-23023 August 1990 Forwards Public Version of Revised Emergency Plan & Corporate Emergency Response Procedures,Consisting of Rev 1 to EPP-313,Rev 7 to CERP-101,Rev 7 to CERP-102 & Revised Forms.W/Dh Grimsley 900906 Release Memo TXX-9029, Responds to NRC Re Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57.Corrective Actions:Storage Facilities for Instrumentation & Control Work Packages Improved to Provide Acceptable Protection for Documents1990-08-20020 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-445/89-57 & 50-446/89-57.Corrective Actions:Storage Facilities for Instrumentation & Control Work Packages Improved to Provide Acceptable Protection for Documents ML20058P0571990-08-13013 August 1990 Forwards, Comanche Peak Steam Electric Station Unit 1 Control Room Simulator 10CFR55 Certification Initial Rept ML20058N2311990-08-0909 August 1990 Forwards First Half 1990 fitness-for-duty Program Performance Data,Per 10CFR26.71(d).Point of Contact for Personnel,Random Testing Program Results & Confirmed Positive Tests Summary & Mgt Summary Included in Data ML20059A5831990-08-0404 August 1990 Responds to Info Request Made During 900802 Meeting Re Inadvertent Safety Injections on 900726 & 30 & Results of 100% Power Plateau Testing TXX-9024, Provides Status of Exam Activity & Revised Completion Schedule for Portion of Exam.Util Deferred Preoperational Testing of Facility Spent Fuel Pool Cooling & Cleanup Sys Until Prior to First Off Loading of Spent Fuel1990-08-0303 August 1990 Provides Status of Exam Activity & Revised Completion Schedule for Portion of Exam.Util Deferred Preoperational Testing of Facility Spent Fuel Pool Cooling & Cleanup Sys Until Prior to First Off Loading of Spent Fuel TXX-9022, Forwards Detailed Descriptions of Changes in Amend 79 to FSAR for Comanche Peak Steam Electric Station1990-07-31031 July 1990 Forwards Detailed Descriptions of Changes in Amend 79 to FSAR for Comanche Peak Steam Electric Station TXX-9027, Responds to NRC Re Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19.Corrective Action:Specific Activity within Tech Spec Limits.No Further Corrective Action Required1990-07-30030 July 1990 Responds to NRC Re Violations Noted in Insp Repts 50-445/90-19 & 50-446/90-19.Corrective Action:Specific Activity within Tech Spec Limits.No Further Corrective Action Required ML20055J1571990-07-27027 July 1990 Submits Info Re Replacement of Borg-Warner/Intl Pump,Inc Check Valve Swing Arms,Per .Swing Arms in ASME Code Class 2 Check Valves Will Be Replaced During First Refueling Outage ML20056A0461990-07-24024 July 1990 Requests Regional Waiver of Compliance for Containment Pressure Transmitter 1-PT-934 During Coming Outage TXX-9023, Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. No Subj Transmitters in Existence at Facility1990-07-18018 July 1990 Responds to NRC Bulletin 90-001, Loss of Fill-Oil in Transmitters Mfg by Rosemount. No Subj Transmitters in Existence at Facility ML20055G6351990-07-17017 July 1990 Submits Results of Remote Shutdown Panel Environ Survey ML20055F9391990-07-13013 July 1990 Advises That Operators Have Gained Significant Experience in Operating Plant Under Wide Range of Conditions & Have Demonstrated Necessary Proficiency to Safely Operate Unit ML20055F9371990-07-13013 July 1990 Submits Info Re Revised Acceptance Criteria for THERMO-LAG Fire Barrier,Per 900705 Telcon.On Exposure to Heat Flux at Surface of Barrier,Listed Mechanisms Activated.Fire Testing Demonstrates That Panels Qualified W/Variation in Thickness ML20044A7001990-06-26026 June 1990 Responds to Generic Ltr 90-04, Request for Info on Status of Licensee Implementation of Generic Safety Issues Resolved W/Imposition of Requirements or Corrective Actions. Util Will Implement for Unit 2 Activities Performed for Unit 1 ML20044A1411990-06-20020 June 1990 Forwards Endorsements 4 & 5 to Nelia Certificate N-90, Endorsements 5 & 6 to Maelu Certificate M-90 & Endorsements 34,35,36,37,38 & 39 to Nelia Policy NF-274 ML20043H7031990-06-18018 June 1990 Discusses Mod/Rework to Auxiliary Feedwater Sys Check Valves Mfg by Bw/Ip Intl,Inc.All But One Affected Check Valve modified.Motor-driven Auxiliary Feedwater Pump Discharge Valve Check Valve Body Replaced ML20043H2181990-06-15015 June 1990 Forwards Response to 900515 Request for Addl Info on Emergency Preparedness.Ongoing Emergency Preparedness Programs Address Concerns Raised by Citizens for Fair Util Regulation ML20043G3131990-06-15015 June 1990 Forwards Addl Info Re Pressurizer Surge Line Thermal Stratification & leak-before-break Evaluation & Nonproprietary Suppl 3 to WCAP-12247, Supplementary Assessment... & Proprietary Suppl 3 to WCAP-12248 ML20043C5671990-06-0101 June 1990 Discusses Identification of Slave Relays Tested Using Alternative Methodology,Per 900402 Commitment.Encl Tabulation Identifies Test Type,Applicable Procedures & Equipment & Impact of Improper Documentation ML20043E7131990-06-0101 June 1990 Responds to NRC 900517 Notice of Violation & Imposition of Civil Penalty in Amount of $25,000.Corrective Action:Qc Mgt Counseled Level III Inspector & QC Supervisor on Importance of Good Communications W/Receipt Inspectors ML20043C4501990-05-31031 May 1990 Advises That Util Revised FSAR Section 15.1.2 & Question/ Response 32.108,per 10CFR50.59 ML20043B5471990-05-25025 May 1990 Provides Status of Facility Design & Const Activities,Per Request.Detailed Design Work Will Resume in June 1990.Const Activities Expected to Increase Signficantly by Jan 1991 ML20043B5481990-05-23023 May 1990 Provides Clarification of 890710 Commitment Re Power Ascension Program.Cooldown Portion of Remote Shutdown Test Performed During Preoperational Testing,Per FSAR & Reg Guide 1.68.2 ML20043D1711990-05-21021 May 1990 Forwards Public Version of Revised Emergency Plan Procedures,Including Rev 8 to EPP-109,Rev 7 to EPP-112,Rev 4 to EPP-116 & Rev 6 to EPP-121.W/DH Grimsley 900604 Release Memo TXX-9018, Advises of Completion of Implementation of Requirements of Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety- Related Equipment1990-05-21021 May 1990 Advises of Completion of Implementation of Requirements of Generic Ltr 89-13, Svc Water Sys Problems Affecting Safety- Related Equipment ML20043B0981990-05-15015 May 1990 Forwards Radial Peaking Factor Limit Rept for Cycle 1, Containing F(Xy) Limits for All Core Planes Containing Bank D Control Rods & All Unrodded Core Planes ML20042F2851990-05-0303 May 1990 Supplemental Response to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey. ML20042F3861990-05-0303 May 1990 Responds to NRC 900410 Ltr Re Violations Noted in Insp Repts 50-445/90-10 & 50-446/90-10 on 900206-07 & 0226-0302. Corrective Action:Memo Issued Emphasizing That Discrepancies Should Be Brought to Attention of Site Organizations ML20042F3021990-05-0202 May 1990 Responds to NRC 900402 Ltr Re Violations Noted in Insp Repts 50-445/89-23 & 50-446/89-23.Util Does Not Believe That Circumstances Described in 900402 Ltr Constitutes Violation of 10CFR50.9(a) ML20042F3051990-05-0202 May 1990 Provides Revised Response to Generic Ltr 88-17 Re Loss of DHR ML20042E4581990-04-12012 April 1990 Responds to Inconsistencies in Terminology & Labelling Identified During NRC 890118 & 19 Audit of Facility Dcrdr. Util Believes Control Room Inventory Requirement of Suppl 1 to NUREG-0737,satisfied ML20042E0701990-04-10010 April 1990 Discusses 900305 Meeting W/Nrc in Rockville,Md Re Offsite Power Availability for Automatic Switch Co Solenoids for MSIV in Event of Nonmechanistic Main Steam Line Crack in Superpipe Region ML20012F5011990-04-0303 April 1990 Forwards Corrections to 891016 Response to Emergency Diesel Generator Engine Requirements.Lengths of Two Pairs of Bolts Above Crankpin Shall Be Measured Ultrasonically Before Detensioning & Disassembly of Bolts ML20012F3221990-04-0202 April 1990 Discusses ESF Sys Slave Relay Alternate Test Methodology. Implementation Schedule for Design Mods to Relay Will Be Submitted by 900601 ML20042D8081990-03-29029 March 1990 Forwards Proposed Change to FSAR Section 13.4 Re Station Operations Review Committee.Similar Change Submitted in 900328 Ltr for Chapter 6 of Facility Tech Specs ML20012F0411990-03-28028 March 1990 Forwards marked-up Pages of Facility Draft Tech Specs & Bases (NUREG-1381) Provided W/Low Power OL ML20012E6051990-03-27027 March 1990 Forwards Endorsements 1-4 to Maelu Certificate M-90, Endorsements 1-9 to Maelu Policy MF-131,Endorsements 29-33 to Nelia Policy NF-274 & Endorsements 1-3 to Nelia Certificate N-90 ML20012E6531990-03-27027 March 1990 Provides Final Response to Reporting Requirement 2 of NRC Bulletin 88-008, Thermal Stresses in Piping Connected to RCS, for Unit.Nde Requirements of Action 2 Not Considered Applicable to Unit ML20012E1911990-03-23023 March 1990 Forwards Comanche Peak Steam Electric Station Unit 1 Cycle 1 Startup Physics Tests Control Rod Worth Predictions Utilizing TU Electric Control Rod Swap Methodology. ML20012E1581990-03-23023 March 1990 Clarifies 880624 Response to NRC Generic Ltr 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. ML20012D0201990-03-19019 March 1990 Advises That Allegations Provided to NRC by Former Util Employee Unsubstantiated,Based on Investigation by Util Safeteam Organization ML20012E2181990-03-19019 March 1990 Responds to Generic Ltr 89-19 Re USI A-47, Safety Implication of Control Sys in LWR Nuclear Power Plants. Util Determined That Loss of safety-related Inverters 1 or 2 Would Involve Coincidental Opening of Main Feedwater Valves 1990-09-04
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of ) Docket Nos. 50-445/83-03
) 50-446/83-01 TEXAS UTILITIES GENERATING )
COMPANY, et al. ) Permits Nos. CPPR-126
) CPPR-127 (Comanche Peak Steam )
Electric Station) ) EA No. 83-64 LICENSEES' ANSWER PROTESTING CIVIL PENALTY On August 29, 1983, the NRC Staff (Region IV) pro-posed a $40,000 civil penalty in the captioned enforce-ment action against Texas Utilities Generating Company, et al. (" Licensees") for an alleged violation of 10 C.F.R. Part 50, Appe'ndix B, Criterion I. Pursuant to 10 C.F.R. I 2.205, Licensees hereby respond to that proposed imposition of civil penalties.
I. Denial of Violation For the reasons set forth in " Licensees' Response to Notice of Violation" (which we incorporate by reference) at pages 2 through 15, Licensees hereby deny in full the o - alleged violation and respect 5ully request that the pro-posed civil penalty be withdrawn or mitigated in full.
Alternatively, Licensees urge that the Staff hold in abeyance any further- consideration of whether the pro-posed civil penalty should be imposed pending judicial 8310050412 830928 PDR ADOCK 05000445PDR G
i review of the Secretary of Labor's Final Decision and Order in Atchison v. Brown & Root,1 on which Final Decision this enforcement action is based. The basis for such request is set forth in Licensees' Response to the NOV at pages 19 through 22, also incorporated by reference.
II. Extenuating Circumstances The extenuating circumstances which Licensees believe warrant the withdrawal or complete mitigation of the proposed civil penalty are set forth in Section IV, below.
III. Error in NOV
'The Staff categorized the alleged violation as Severity Level III and proposed the S40,000 base civil penalty for alleged violations of that severity level.
Licensees submit that the alleged violation should have been characterized as Severity Level IV and that, as specified in the Enforcement Policy, no civil penalty should have been proposed.2 1 Atchison v. Brown & Root, Inc.; 82-ERA-9; June 10, 1983; appeal pending sub nom.; Brown & Root v.
Donovan, No. 83-4486 (5th Cir.).
2 See 10 C.F.R. Part 2, Appendix C at Tables lA and 1B and { IV.B.
f As discussed in detail in Licensees' Response to the
-NOV, the Secretary'did not make any findings with respect
- to possible safety impacts of the violation of Section 210 of the Energy Reorganization Act. Nor did the Secretary make any findings concerning the adequacy of Licensees' OA/QC program.3 In addition, the Staff itself made no independent findings on either of these matters. Its investigation of Atchison's original allegation did not substantiate or refute the claim of wrongful discharge under Section 210 of the Energy Reorganization Act and did not reveal .any safety or programmatic issues raised by those claims.4 i- Similarly, the Licensing Board in the Comanche Peak operating license proceeding found that the Secretary's Decision did not address any safety questions and was not dispositive one way or the other as to whether this incident was an isolated occurrence.5 Finally, the Staff's recent investigation confirmed that there was no chilling effect on the issuance of NCRs due to Mr.
l l -
3 Licensees' Response to the NOV at 4-7.
4 Inspection and Enforcement Report 82-10 and 82-05; Texas Utilities Generating Co. (Comanche Peak Steam Electric Station, Units 1 and 2); June 30, 1982 at 2.
5 Texas Utilities Generating Co. (Comanche Peak Steam Electric Station, Units 1 and 2); Docket Nos. 50-445, 50-446; Memorandum and order (Collateral Estoppel; Atchison Case); July 6, 1983 slip op at 4-5.
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Atchison's discharge.6 Thus, the investigation revealed I no safety or programmatic problems. Accordingly, because i
there is no evidence of systemic deficiencies in Licensees' QA/QC program, Licensees submit that the alleged violation should be categorized as a Severity Level IV. It clearly should not be treated by the Staff as a "significant" violation of NRC Regulations and thus categorized as Severity Level III.7 This view is confirmed by comparing the alleged violation in this enforcement action with analogous enforcement actions recently taken by the Staff. On October 5, 1982, the NRC Staff (Region III) proposed a
$40,000 civil penalty against Illinois Power Company for alleged Severity Level III violations of Appendix B, i
Criterion I at Clinton.8 In addition, on November 24, 1981, the NRC Staff proposed a $50,000 civil penalty against Cincinnati Gas & Electric for an alleged Severity 6 Inspection and Enforcement Report 83-34 and-83-18; Texas Utilities Generating Co. (Comanche Peak Steam Electric Station, Units 1 and 2); September 12, 1983.
7 A Severity Level III violation is of "significant concern to NRC" while a Severity Level IV violation is of "more than minor concern. . . . " 10 C.F.R. Part 2, Appendix C, 5 III.
8 The $40,000 civil. penalty was one component of a
$90,000 total civil penalty. Illinois Power Company (Clinton Nuclear Power Station); Docket No. 50-461; Notice of Violation and Proposed Imposition of Civil Penalties; October 5', 1982.
Level III violation of Appendix B, Criterion I at !
Zimmer.9 In both of these cases, the Staff alleged numerous incidents which it claimed indicated systemic deficiencies in OA programs.
The Staf f in this enforcement action, however, alleged only one isolated incident which it claimed constituted a violation of Criterion I, and never even directly related that incident to Appendix B. It then proposed a sanction which was virtually identical to Accordingly, to those proposed in Clinton and Zimmer.
reflect the significance of the instant case relative to Clinton and Zimmer, Licensees submit that the alleged violation here should be categorized as Severity Level IV, not Severity Level III.
Licensees recognize that there has been corsiderable publicity surrounding the Atchison case because of the However, undue pendency of the Comanche Peak OL case.
sanctions should not be imposed on the Licensees simply In addition, the because the case is celebrated.
Director of the Office of Inspection and Enforcement must
', assure that consistency in enforcement sanctions is main-l tained between the various NRC regional offices so that 9 This was one component of a $200,000 total civil penalty. Cincinnati Gas & Electric Co. (William H.
Zimmer Nuclear Power Station); Docket No. 50-358; Notice of Violation and Proposed Imposition of Civil Penalties; November 24, 1981.
i P
an NRC licensee does not suf fer (or benefit) because it is lc0ated in one Region rather than another. It is in this light that Licensees have presented here the com-parison of the instant case with the Clinton and Zimmer cases, a comparison that we believe compels the conclu-sion that the Staff should reclassify the instant case as Severity Level IV.
IV. Other Reasons Why the Proposed Penalty Should Not Be Imposed Even if the alleged violation was properly cate-gorized as Severity Level III, Licensees submit that the Staff should exercise its discretion in this enforcement action and not impose the base civil penalty for the alleged violation. Instead, recognizing that the objec-tive of any civil enforcement action should be to remedy rather than punish, the Staff should ndtigate the pro-posed civil penalty in its entirety to reflect the unique facts in this case.
While the Secretary may have found a violation of Section 210, the record before the Department of Labor confirms beyond doubt that the QC inspector " repeatedly misrepresented facts about his background."10 In fact, the Secretary ordered that the inspector not be reinstated to his former job because of his 10 Secretary's Decision at 27.
1
. l 1
1 l
prevarications.ll Moreover, the Administrative Law Judge at Labor found that the QC inspector " lied on his application for Brown and Root in employment when he stated he received an associate's degree from Tarrant County Junior College . . . [;]" " physically altered a copy of the Tarrant County Junior College reply to Brown and Root to reflect his achievement of a degree and then J
used this altered form as part of his January, 1982 application for TUGCO employment [;]" and made
" misstatements at points under oath" in connection with July, 1982 hearings.12 The evidentiary record in the Comanche Peak OL case before the NRC supports the same findings.13 Under these circumstances, where the discharged QC inspector is found to be flatly dishonest, Licensees t submit that the Staff should withdraw (or mitigate to zero) the proposed civil penalty. Further, the QC in-spector discharged is not of the competence of other QC inspectors at Comanche Peak, and his treatment can there-fore in no way be considered indicative of the treatment 11 Id. at 25-27.
12 Atchison v. _ Brown & Root; Case No. 82-ERA-9; December 3, 1982, Recommended Decision at 3.
13 Texas Utilities Generating Co. (Comanche Peak Steam Electric Station); 50-445 and 50-446; Transcript of l Operating License Proceedings at 3270-71, 3340-41,
! 3356-57 and CASE Exhibit 650A at 1.
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afforded'other QC inspectors. The recent Staff investi-gation concluding that Mr. Atchison's discharge had no chilling effect on th( issuance of NCRs confirms that QC inspectors feel free to report non-conforning conditions.
In view of those unique facts, Licensees urge that the Staff exercise its discretion and reduce the proposed civil penalty.
V. Mitigation The Enforcement Policy provides that the Staff may mitigate a proposed civil penalty by 50% in the event of unusually prompt and extensive corrective action.14 The Enforcement Policy also expressly provides that after the Staf f has mechanistically applied the Policy to arrive at a preliminary penalty, the Staff will then exercise judgment and discretion when determining the appropriate enforcement sanction.15 Based on the exercise of such discretion, the .Staf f has in the past mitigated proposed civil penalties in fu11.16 14 10 C.F.R. Part 2, Appendix C $ IV.B.2.
15 Id. at 5 I.
16 E.g., August 16, 1983 letter from Richard C. DeYoung, Director, Office of Inspection and Enforcement, U. S.
Nuclear Regulatory Commission to Mr. Warren Murphy, Vice President and Manager of Operations, Vermont Yankee Nuclear Power Corp.: Appendix at 3 (mitigating in full proposed civil penalty in EA-83-34); October 5, 1982 letter from Richard C. DeYoung, Director, Office of Inspection and Enforcement, U. S. Nuclear (footnote continued)
4 i
i Licensees submit that in view of the narrow scope of the alleged violation, the unique facts underlying this enforcement action set forth in the preceding section of this Answer, and the aggressive and comprehensive respon-sive actions now being implemented, complete mitigation of the proposed civil penalty is warranted.
As described in detail in Section III of Licensees' Response to the Notice of Violation (which is incor-porated herein), Licensees are taking several additional steps to assure that incidents of this nature do not occur and to assure that no employee at Comanche Peak is inhibited in any way from expressing his or her concerns with respect to quality related work at the site. These responsive actions are convincing evidence that
~
Licensees' management is concerned and will act promptly 1
and forcefully to assure that management control of the OA/QC program is firm and that the necessary independence of that program from cost and schedule considerations is reaffirmed. In these circumstances, the Staff's enforce-ment action has already accomplished its intended (footnote continued from previous page) .
Regulatory Commission to Mr. W. G. Counsil, Senior Vice President, Nuclear Engineering and Operations, Northeast Nuclear Energy Company at 2 (mitigating in full proposed civil penalty in EA-82-33).
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results, and no purpose would be served by imposing a monetary penalty. Thus, the proposed civil penalty should be mitigated to zero.
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VI. Conclusion For the reasons set forth above, Licensees request '
that the proposed civil penalty be withdrawn or mitigated ,
in full.
Septedber 28, 1983 4
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